The new applicability date for the fiduciary-level fee disclosure rule under Section 408(b)(2) of the Employee Retirement Income Security Act (ERISA) has been extended from July 16, 2011 to April1, 2012. This extension date is three months later than the proposed deadline extension.

The transitional rule in the final rule for the participant-level disclosure rule is amended to require that initial disclosures be furnished by the later of

60 days after a first day of the first plan year beginning on or after November 1, 2011, or

60 days after the effective date of the fiduciary-level fee disclosure rule.

The transitional rule also provides that certain quarterly disclosures must be furnished no later than 45 days after the end of the quarter in which the initial disclosures are required to be furnished to participants and beneficiaries under the transitional rule.